2019 Annual Report on Managing Conflicts of Interest: White Paper

April 1, 2021
April 1, 2021

The management of Conflicts of Interest (COI) can vary widely across healthcare organizations. Effective and comprehensive COI programs are often dependent on the level of leadership buy-in demonstrated in their support. When executive leadership appreciably champions these programs, organizations typically exhibit a thorough, disciplined approach. When leadership buy-in is nonexistent, the COI management approach is often more haphazard. In today’s healthcare landscape, the assurance of a conflict-free environment has never been more important; therefore, organizations need to take the appropriate steps and action to achieve this environment.

A conflict of interest is defined as a situation in which a person is in a position to derive personal benefit from actions or decisions made in their official capacity. An example might be a physician who benefits financially from prescribing a certain drug or a corporate executive who buys all office supplies from a company owned by a family member.

Over the past several decades, the U.S. government has increasingly cracked down on these types of improprieties and has enacted a number of measures to prohibit their occurrence and promote greater transparency. Some of these measures include:

Measures Promoting Greater Transparency

  • Anti-Kickback Statute prohibits referrals for any kind of item or service where a kick-back is involved
  • Stark Law curbs physician referrals to entities in which they have a financial relationship
  • The Sunshine Act (part of the Affordable Care Act) – requires drug and device manufacturers to report physician and teaching hospital payments in excess of $10
  • IRS Form 990 – increases transparency and disclosure of non-profit and teaching hospitals’ operations
  • CMS Open Payments Database – database compiled and made available on the federal level and lists payments made to physicians and teaching hospitals by drug and medical device companies required under The Sunshine Act

In this white paper, HCCS—A HealthStream Company, surveyed 281 healthcare compliance leaders throughout the U.S. to learn more about the compliance programs in their hospitals. HCCS wanted to discover how well Conflicts of Interest were being monitored and uncover any gaps in the process. We hope this information is helpful to your organization and informs your decision-making with regard to compliance monitoring and reporting.

Download the white paper, with key findings about the current state of healthcare COI management, here.


Learn how HCCS can help you manage healthcare conflicts of interest (COIs) at your organization.